Effective Date: August 19, 2021
We are all increasingly aware of companies who stress that the safety of your data is of paramount importance. Well for us, as a provider of lone worker services, protecting people can quite literally be a case of life and death. At SoloProtect, protecting people is in everything we do and the trust our customers (your Employers) place in us extends to our privacy practices.
This policy describes the information we collect or is shared with us by your Employer, how it is used, stored, and safeguarded, and your choices regarding this information.
If you are an Account Administrator, Information Governance professional, or a member of your Employer’s Legal or Privacy team we encourage you to integrate the contents of this policy into your own policies, procedures, and notices as they apply to your use of our services.
- Privacy Statement
This policy outlines how we at SoloProtect collect and use personal information to provide our services. This policy applies to all individuals who, through their Employer, interact with us or our services as they are delivered by SoloProtect US LLC and/or its affiliates.
Specifically, this policy applies to:
- Account Representatives and Billing Contacts: these are individuals responsible for the establishment of the contract with SoloProtect and its day-to-day operation, including ensuring that we meet our commitments, facilitating the purchase of SoloProtect Devices, resolving any issues should they arise or our principal contact for the purposes of receiving and paying our invoices.
- Account Administrators and Escalation Contacts: these individuals are responsible for the management of the services at the Employer as well as the key contacts we call should an incident occur with a Device User.
- Device Users: these are the individuals our services are designed to protect and include any individual the Employer (our customer) has issued a SoloProtect Device to. SoloProtect Devices include any of the following: SoloProtect ID, SoloProtect Mobile App, or any Identicom-series device.
We refer to all individuals covered by this policy collectively, however, our use of your data and our reasons for doing so will depend on how you interact with us and the services we provide, and it is important for you to read this policy in full to understand exactly how it applies to you.
This policy also applies to those who provide information to SoloProtect in connection with a request to use our services (where we have provided access to the services or SoloProtect Insights) or for those trialling our services.
HOW TO CONTACT US ABOUT YOUR RIGHTS AND DATA
For any questions or comments about this policy or, more generally, about SoloProtect’s data protection practices you can contact our Data Protection Office as follows:
By email at: email@example.com
INFORMATION COLLECTED OR SHARED WITH US
The following information is either collected by us or shared with us by your Employer:
1. Information provided directly to us (Submitted Information)
This is information you or your Employer provide us directly, either to our Customer Services team or through SoloProtect Insights and includes:
- Personal Master (or Key Personal Data): if you are a Device User, Administrator, Escalation Contact, or any other person issued with a SoloProtect Insights account you will be required to make a profile. This profile may include your name, job title, company name, email address, contact telephone number, date of birth and gender.
- Medical Data (optional): if you are a Device User, we give you the option of providing any information about your health or medical history that you feel might be required should we need to send the emergency services out to assist you. SoloProtect Insights allows you to enter whatever medical information you feel is appropriate, but typically Device Users include their blood type, any known allergies, any known medical conditions, and any medication they may be taking.
- Work Pattern Details: this predominantly includes your hours and place of work, as well as any other similar information such as whether you work shift patterns. For most of our services, the supply of this information is optional. However, for our MWM - mobile workforce management - services or where you are supplied with the SoloProtect Mobile App, your Employer may require this information from you to ensure passive information (such as location data) is only collected during your hours of work.
- Vehicle Details: if you are a Device User who is very mobile as part of your job (such as a home healthcare worker or a logistics driver) your Employer may require that you enter your Vehicle Details (be it a company or personal vehicle), including your vehicle make, model, colour, and registration number. This information is used to better allow any emergency services we dispatch to locate you.
- Other identity details (optional): while our EDC Operators are all highly trained in both monitoring alarms and dispatching the emergency services (when necessary), we like to ensure that those first responders have as much information as possible to be able to identify you. To that end, Device Users are given the option to enter typical identification information about themselves, such as height, weight, physical description, and ethnicity.
2. Information created when you interact with our services (Passive Information)
This is information about you that is created as you use a SoloProtect Device, SoloProtect Insights or interact with us in any way and includes:
- Location Data: our Devices utilisze GPS technology to determine your current location; if we do not know where you are, we cannot let your Employer or the emergency services know in the event you activate your Device. In addition, if you are using SoloProtect Mobile (the “App”) we do this by collecting the location data of your mobile device and when you install the App you will be asked to consent to your mobile device’s geolocation data being used for this purpose. If you permit the App to access location services through the permission system used by your mobile device, we will also be able to collect your precise location when the App is running in the background.
- Audio and Communications Data: communication is how our Devices work, be it in the case of our EDC Operators monitoring an incident, or communication two-way when an incapacitation alarm is triggered. When we communicate with you, we keep a record of that conversation. In addition, our EDC Operators also make a written record of every incident that happens over a SoloProtect Device; we call this an EDC or Incident Record. Both these pieces of information can be very useful evidence should your Employer wish to take further action against a person who may have verbally or physically abused you; we are also required to produce these in line with our own regulatory requirements. We differentiate the types of Audio and Communications Data we produce by incident type (i.e., whether the incident was “false”, “genuine” or “genuine with the dispatch of emergency services”).
- Customer History: to allow us and your Employer to monitor our performance in delivering our services we keep a record of how we deliver those services. We call this a Customer History and it will often contain a log of all incidents received per Device User per Device (along with the location of the Device User at the time of that incident), usage figures of our Devices (including statistical information on the number of incidents per Device User per Device and severity of those incidents), changes made by your Employer to your account, and a conversation history of all communications made between you and our customer services team relating to your use of our services.
3. Other information
This includes the various other information we need to deliver our services to you and your Employer and includes:
- For SoloProtect Mobile App: Each time you visit the App or use the services we will automatically collect various technical information about your mobile device, including the type of mobile device you use, a unique device identifier (for example, your Device’s IMEI number, MAC address, and the mobile phone number), mobile network information, your mobile operating system, the type of mobile browser you use, and time zone setting.
- Key Contract Data: this includes any information we collect directly from an Account Representative to allow us to manage the contractual relationship with your Employer, including your name, job title, email address and contact telephone number.
- Financial Data: this includes any information we collect directly from an Account Administrator or Billing Contact to allow us to send invoices, receive payments and facilitate refunds and includes your name, job title, email address and contact telephone number.
- Contact Data: this includes any information we collect directly from an Account Administrator or Escalation Contact to provide the services to you, Devices Users and your Employer and includes, your name, job title, email address, contact telephone number. Both Account Administrators and Escalation Contacts may also be provided with a SoloProtect Insight’s account and we, therefore, will also collect Key Personal Data should you choose to provide this.
- Contract Billing, Payments Data and Cardholder Data (corporate cardholder data only): while any data collected here will, for the most part, be corporate data (i.e., data about your Employer and not about you), it may still include your personal information (such as your name, job title, place of work, contact details). We collect this information to send invoices, receive payment and to facilitate refunds. With regards to Cardholder Data, this only extends to cardholder information for a business card issued to you by your Employer; we do not accept nor collect personal cardholder information.
HOW WE USE YOUR INFORMATION
We collect, process, store and disclose personal data for a variety of different reasons all of which are related to our services. We do not sell, share, disclose or use your data for anything else not covered by the below; we use your data to provide our services and only our services.
Those services are as follows:
- Audio-enabled lone worker services: you are receiving these services if your Employer has supplied you with any of the following SoloProtect Devices: SoloProtect ID, SoloProtect Mobile or any Identicom-series device.
- Mobile workforce management services: you are receiving this if you have been issued with a Latest location feature for your SoloProtect Device or on your mobile device.
- SoloProtect Insights: our customer-engagement portal.
Use Cases for those Services
1. Audio-enabled lone worker services
(i) To monitor you discreetly and remotely in the event you activate your SoloProtect Device and, if necessary, inform either your Employer or the emergency services about that incident.
(ii) To monitor your location whilst you are using a SoloProtect Device and, in the event you activate your Device, pass your location to your
Employer and the emergency services so they can locate you.
2. Latest Location
(i) To monitor your location while you are using a SoloProtect Device to allow us and your Employer to provide useful safety-related information to you about your surroundings (such as risk-based messaging).
(ii) To allow your Employer to monitor your location, including where you have been (known as “breadcrumbing”). Your Employer’s policies and processes on how and why they use this information should be communicated to you by them. However, this is typically used to allow your Employer to manage its mobile workforce (such as if you are a logistics or delivery driver).
3. SoloProtect Insights: SoloProtect Insights is our customer-engagement portal and is a very useful resource both for you and your Employer. It provides you with the ability to manage your profile and add/update/delete information as you require. It also allows your Employer to manage the services, such as by adding new Device Users (which could extend to them inputting information about you on your behalf), access reporting information relating to safety-related incidents, and engaging with our customer services team.
4. Other and Special Category Data: certain information we collect, or process is particularly sensitive, and we use that information as follows:
(i) Medical Data: adding medical data to your profile is entirely optional, but if you do, we ask that you consent to our using of this data to keep you safe and in line with this policy. We ask for that consent through SoloProtect Insights or through our profile onboarding forms (which your Employer may supply to you). We only use your medical data to keep you safe; should you activate your Device and, based on the incident, our EDC Operators decide to send the emergency services to assist you, we would share any necessary medical data with the emergency services.
(ii) Audio (Communications) Data: audio relating to any Device activations is recorded. Audio data is differentiated by incident type - i.e., depending on whether the incident was “false”, “genuine” or “genuine with the dispatch of emergency services”. Should you activate your Device and, based on the incident, our EDC Operators may decide to involve the emergency services (particularly the police), we may choose to share live audio data with the emergency services to assist them in assessing the urgency of any required response. We may also share audio data for genuine incidents with your Employer to allow them to decide if they wish to take further action against a person who may have verbally or physically abused you.
(iii) Cardholder Data (corporate data only): some of our customers choose to pay for our services through card transactions, specifically by providing their cardholder details to our finance team (known as “card not present transactions”). We use this data solely to facilitate those payments and use a secure payment processor (Forte) to do so and we are compliant with the applicable standards for handling cardholder information (PCI DSS).
We may transfer your personal data to third party suppliers based outside the United States (US), for example, for billing purposes. Where we do so, we will only transfer personal data that is entirely necessary for us or a supplier to provide their services. If you require further information about this, you can request it from firstname.lastname@example.org.
COOKIES AND OTHER TECHNOLOGIES
Cookies come in a variety of forms but are essentially small data files used to collect and store information about you. We use them on SoloProtect Insights for a variety of different functions:
- for the smooth and safe operation of SoloProtect Insights.
- to manage your preferences and remember you for future visits.
- to analyse how you use SoloProtect Insights to continually make improvements.
Most of these cookies are linked to your browser session (session cookies) and disappear once you close your browser. Others remain on your device for a longer period (persistent cookies).
The California Consumer Protection Act (“CCPA”) protects a California resident’s right to request access to or deletion of their personal information (with certain exceptions). The categories of data that we may use or share with third parties is described in this Privacy Statement.
If you reside in California:
- You have the right to request that we disclose the personal data we collect, use, disclose and “sell” about you over the past 12 months; and
- You have the right to request that we delete any of your personal data that we collected from you and retained, subject to certain exceptions.
You may submit a request to us, request more information, or inquire on exercising your rights under the CCPA, at email@example.com. You may also submit a written request to us at 701 Canyon Dr., Ste 105, Coppell Texas 75019. We may take reasonable steps to verify your identity and the authenticity of the request. We will not discriminate against you for exercising any of your CCPA rights.
Nevada law provides that where certain types of personal information (“Covered Information”) are collected via a website or online service maintained by the operator of such site, that the operator notify the consumer of the categories of information collected, how it is collected, shared, used, and where applicable, accessed by third parties. That information is provided by this Privacy Statement.
Certain Nevada consumers may opt out of the sale of “personally identifiable information” for monetary consideration to a person that license or sell such information to additional persons. “Personally, identifiable information” includes first and last name, address, email address, phone number, Social Security Number, or an identifier that allows a specific persona to be contacted either physically or online. We do not engage in such activity; however, if you are a Nevada resident who has purchased or leased goods or services from us, you may submit a request to opt out of any potential future sales under Nevada law by contacting firstname.lastname@example.org. We may take reasonable steps to verify your identity and the authenticity of the request.
UPDATES TO OUR POLICY
It is important that you revisit this policy regularly, as we may change its content and the other policies of our Privacy series as we further enhance our product range and improve our services. If we make any major changes, or any changes which directly affect the services provided to you or the data collected or processed by us, we will notify you of those changes.
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